This is now part of our working future, but many items are either proposed for review or actively being reviewed as we speak. 

Many of these legislative reviews have yet to crystalise into legislative change but, none the less, trade sssociations such as BCAS and lobby groups have been very active on your behalf. 

The recent 'UK Product Safety Review' consultation is a case in point; we are used to working with the legacy legislation but must now work with Government as it looks at the long-term approach to product safety and how to ensure that the regulatory framework is fit for the future. 

Along with the UK ErP (Energy-related Products) Policy Framework proposal, this demonstrates the drive to review legacy legislation and it is critical that all stakeholders are represented in this process. This is where relationships between trade associations and government departments are critical, so that we can consolidate the voices of many into clearly communicated positions, ensuring that industry is represented.

UKCA marking update

Further to previous updates on the deadline for the end of the recognition of CE Marking (which remains at 11pm on 31 December 2022), in June 2022 the UK Government announced a range of changes to make it simpler for businesses to apply new UKCA product conformity markings for most products placed on the market in England, Scotland and Wales (‘GB’).

The new measures attempt to reduce the burden on British businesses in achieving the necessary conformity. The UK Government’s intent of these easements is to:

• Reduce re-testing costs
• Remove the need to re-test existing imported stock
• Continue to accept spare parts onto the GB market
• Extend labelling measures
• Recognise historic testing on some construction products

Please ensure that you check how these easements apply to you and your business, or seek further advice, as we are getting ever closer to the date when the UKCA Marking requirements are fully implemented. 

The harmonised standards cited in the Official Journal of the European Union (OJEU)  for CE marking have become ‘designated’ standards  – the list of standards allows businesses to show compliance with legislation (see www.gov.uk/guidance/designated-standards),

The intended benefit to end users is that there should be significantly less likelihood of the predicted interruption to supply chains. GB importers of European produced goods can supply to the market without the full burden of third-party assessment testing of goods, where technical files are in place for the CE marking system and where goods are already known to comply with the requirements. 

Please note that, after 2022 (when application of the UKCA Marking becomes mandatory), when an EU Conformity Assessment document moves past its validity date or a new product is placed on the market (after 2022), full UKCA Conformity Assessment requirements will have to be observed (Northern Ireland has its own regulations).

Suggested links:

• www.gov.uk/government/news/government-to-make-it-simpler-for-businesses-to-apply-new-product-safety-markings
• www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain
• www.gov.uk/guidance/using-the-ukca-marking

UK ErP update

In alignment with the EU Ecodesign framework policy, the UK Government department for Business, Energy and Industrial Strategy (BEIS) has launched a UK ErP (Energy-related Products) Policy Framework proposal, through its ErP team. The purpose of the ErP team is to:

• regulate the market (remove the least efficient products from being placed on the market),
• promote clear and consistent energy labelling of products to educate purchasers,
• encourage the use of the Energy Technology Lists to encourage use of the most energy efficient products,
• promote resource efficiency and the 'Right to Repair',
• monitor and understand the impacts of any divergence from EU legislation.

Several product categories have been identified and some existing products (such as lighting products and electric motors) are already adopted. For the air compressors market, product categories identified for further investigation are 'standard', 'low-pressure' and 'oil-free' air compressors. 

BCAS has been engaged with this process, specifically for the air compressors' market via the initial stakeholder meetings. This is with the aim of ensuring that our members (including users, distributors and manufacturers of compressed air and low-pressure equipment) have a voice in the process, assisting in producing an output framework for air compressors that will be relevant, useful and practical.

Through engagement with the ErP team, BCAS has sought to direct the focus of the consultation toward a system-based approach, rather than focusing on the regulation of products (which, in most cases, are already highly optimised to give the best efficiency possible). 

In the simplest example, you can manufacture an energy efficient light bulb, but if it is left switched on, you are still not optimising energy efficiency. Managing compressed air usage can maximise the potential energy savings from specific applications, and we encourage operators of compressors to ensure that the systems currently in place for distribution and treatment of the compressed air are optimised for energy efficiency. 

To support this activity, BCAS is promoting the adoption of a periodic, compressed air system energy audit (to ISO 11011), along with accredited training and qualification. This will ensure that end users receive a reliable, consistent audit report, ideally with an incentivised implementation policy.

BCAS is also developing an industry performance data verification scheme, with an associated independent, third-party verification element. This is intended to provide users with reliable, consistent, validated compressor performance data, enabling direct comparison between suppliers. 

The key to making good management choices is visibility and without a clear and consistent measure of specific power being available, consumers have very little opportunity to make an initial direct comparison. 

We (as consumers) are very used to the motor vehicle performance test numbers for fuel economy. But, in fact, we have no such industry standard obligation for manufacturers today, and while many willingly work towards a clear labelling of their products it can not be said that this is regulated for the industry.

With all this activity ongoing it is more important than ever that you remain in touch with the proposed changes and have your say on what could be our new legislative landscape.

Tim Preece is technical officer at the British Compressed Air Society

www.bcas.org.uk

Tel: 020 7935 2464